Anti-Corruption Report featured anti-corruption & international risk co-chair Ryan Rohlfsen in the third installment of its four-part series on how companies should reassess compliance risks amid shifting enforcement priorities.
Ryan emphasized the importance of revisiting assessment cadence in light of ongoing change, “Right now, a lot is changing in terms of enforcement risk and the righting of priorities such that it may be worth doing a risk assessment this year or next year as more clarity is gained — even if that would not be part of an organization’s ‘normal’ cycle.”
He also cautioned against relying on outdated analyses in a dynamic environment, “Legacy risk assessments can come under scrutiny when issues surface later,” he said. “Whenever that happens, even when there is just an allegation and nothing has been confirmed, people within a company will start asking whether it did a risk analysis, whether it did its due diligence on a third party, and those legacy risk assessments will be pulled and reviewed.”
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